Summary
The United States District Court for the Northern District of Illinois reviewed the Commissioner of Social Security’s denial of Helen L.’s application for disability benefits. The court held that the Administrative Law Judge adequately accounted for Helen L.’s moderate limitations in concentration, persistence, and pace, and affirmed the Commissioner’s decision.
Holdings
- The ALJ adequately accounted for Plaintiff's moderate concentration, persistence, and pace limitation by limiting her to simple instructions and simple work-related decisions, with sufficient persistence, concentration, or pace to timely and appropriately complete job duties, together with other restrictions supported by the record.
- The ALJ's evaluation of Plaintiff's subjective symptoms and the medical and other evidence was adequately explained and supported by substantial evidence.
Questions Presented
- Whether the ALJ's residual functional capacity assessment adequately accounted for Plaintiff's moderate limitation in concentration, persistence, and pace.
- Whether the ALJ's evaluation of Plaintiff's symptoms and the supporting medical and daily-activity evidence was supported by substantial evidence.
Disposition
affirmed
Cases Cited (22)
- Cain v. Bisignano, No. 24-1590, 2025 WL 2202133, at *3 (7th Cir. Aug. 4, 2025)(followed)
- Crowell v. Kijakazi, 72 F.4th 810, 813-14 (7th Cir. 2023)(followed)
- Biestek v. Berryhill, 587 U.S. 97, 97, 103 (2019)(followed)
- Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008)(followed)
- Green v. Astrue, No. 11 CV 8907, 2013 WL 709642, at *7 (N.D. Ill. Feb. 27, 2013)(followed)
- Warnell v. O’Malley, 97 F.4th 1050, 1053-54 (7th Cir. 2024)(followed)
- Thorlton v. King, 127 F.4th 1078, 1081 (7th Cir. 2025)(followed)
- Jeske v. Saul, 955 F.3d 583, 587 (7th Cir. 2020)(followed)
- Bakke v. Kijakazi, 62 F.4th 1061, 1066 (7th Cir. 2023)(followed)
- Varga v. Colvin, 794 F.3d 809, 813 (7th Cir. 2015)(followed)
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Court Document
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